The European Chemicals Agency (ECHA) has invited feedback from the Partners Expert Group on its Draft Guidance Document on Requirements for Substances in Articles (version 4.0).

Orgalime welcomes the opportunity to comment on this draft. While we acknowledge the complexity of the ECHA’s task and are fully committed to complying with all legal provisions, we are seriously concerned that a proportionate and workable implementation of Article 33 REACH on the basis of the draft ECHA Guidance in its present form will be impossible for companies in our sector – particularly for SMEs.

In this position paper, Orgalime presents its recommendations on how the draft ECHA Guidance can be improved: by providing further clarification on key definitions, and by adopting practical and proportionate solutions that will simplify compliance while ensuring effective enforceability of the REACH articles in question.